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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #98-0244 ([National Propane Gas Association] [Mr. W. H. Butterbaugh])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: National Propane Gas Association

Individual Name: Mr. W. H. Butterbaugh

Location State: DC Country: US

View the Interpretation Document

Response text:

OCT 19, 1998

Mr. W. H. Butterbaugh                Reference No.: 98-0244

Senior Technical Advisor

National Propane Gas Association

1101 17th Street, N.W., Suite 1004

Washington, D.C. 20036

Dear Mr. Butterbaugh:

This responds to your letter of August 18, 1998, concerning the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether propane cylinders are subject to the requalification requirements of the HMR when owned by private individuals who take them to propane marketers to be refilled.

Your understanding is correct. As specified in §171.1, the HMR govern the safe transportation of hazardous materials in intrastate, interstate, and foreign commerce. "In commerce" excludes from regulation the transportation of hazardous materials in a private vehicle where the material is for personal use. Thus, in the situations you describe in your letter, the propane cylinders are not subject to the requalification requirements of the HMR.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.


Thomas G. Allan

Senior Transportation Regulations Specialist

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions